Epstein Secrets

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

iverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records

25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Co field (David Seth Kokin) LAS VEGAS, NV 89135 84. 85 Michael Fisten Weston, FL 86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL, 33480 89. Beata Banasiak 358

407 A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: Q: Do you, is she neither would you agree that neither Jane Doe nor L.M. have testified to any, that they had any connection whatsoever with Ghisl

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

the manner in which the cases were handled while Edwards was a partner at RRA: Q: The one meeting that you had in Mr., Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done or certain tactics should be

ung girls were also blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was force

osed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Becau

question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12

ET-PREVOST, COLT & MOSLE LLP 22 EFTA00708314 Case 09-34791-RBR Doc 1603 Filed 04:08:11 Page 23 of 23 SLATKIN & REYNOLDS, P.A. Attorne s for Russell Adler and Katie Adler ILEANA CRUZ BONGINI, ESQ. STEARNS WEAVER MILLER an WEISSLER ALHADEFF & SITTERSON, P.A. ASSOULINE & BERLOWE, P.A. (VIA CM/ECF an

-23. A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: 6 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00585399 Q: Do you, is she neither would you agree that neither Jane D

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

the manner in which the cases were handled while Edwards was a partner at RRA: Q: The one meeting that you had in Mr., Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done or certain tactics should be

otd Notice of Taking Deposition Ghislane Noelle Maxwell 08/07/2009 85 Notd Notice of Taking Deposition

08/07/2009 84 Notd Notice of Taking Deposition Ghislane Noelle Maxwell 08/07/2009 85 Notd Notice of Ta

202 Noh Notice of Hearing 1/27/2011 01/21/2011 203 Mot Motion To Expand Interrogatories 01/21/2011 204 Ncan Notice of Cancellation Of Depo of Russell Adler 01/21/2011 205 Ncan Notice of Cancellation Of Depo of Herb Stettin 01/24/2011 206 Ncan Notice of Cancellation Depo of Ken Jenne 01/24/2011 207 M

ut I am just going through the questions that refused to be answered at this time. Next it discusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she neither -- would you agree that neither Jane Doe nor LM" -- who are, again, Mr. Edwards' two clients

scusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she ne

handled while Edwards was a partner at RRA, the meeting he had with Mr. Rothstein. We asked: "The meeting you had in Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done, certain tactics should be

es Estrada Bradley Edwards Improper Serving of Maxwell Joint WI() Priv. 05105-05107 04/20/2009 Bradle

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 20888 09/12/2009 Russell Adler Bradley Edwards Potential New witnesses W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of adm

6107 08/11/2009 Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege 16123-16124 08/11/20

ant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Productattorney client 28 EFTA00310075 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & L

ed to lead to the discovery of the admissible evidence; protected by privacy rights 06540-06541 09/21/2009 Bradley Edwards Mike Fisten Info on Maxwell Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 Russell Adler Bradley J. Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery

6107 08/11/2009 Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege 16123-16124 08/11/20

ant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Product;attorney client 28 EFTA00602862 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos &